103 



does not have this system in place. More significantly, 

 with the exception of some limited funding for work on the 

 northern spotted owl (Strlx occidentalls) , the BIA and 

 Tribes have not received funding to comply with the 

 Endangered Species Act on trust lands. 



ENVIRONMENTAL ASSESSMENT ISSUES 



The project proposes a solution to a dilemma faced by 

 the Bureau of Indian Affairs over the management of trust 

 range resources. On one hand, the BIA has a trust 

 responsibility to the Tribe to effectively manage trust 

 lands which currently have unacceptable concentrations of 

 prairie dog colonies for agricultural production. On the 

 other hand, the BIA has a responsibility to comply with the 

 Endangered Species Act as it pertains to the recovery of 

 endangered and threatened species, such as the black- footed 

 ferret . 



In 1991, the BIA proposed to conduct limited poisoning 

 of prairie dogs on the Cheyenne River and Rosebud Sioux 

 Reservations and completed an Environmental Assessment (EA) 

 pursuant to the National Environmental Policy Act (NEPA) and 

 the Endangered Species Act. The BIA lacks sufficient 

 funding, personnel and time to meet the U.S. Fish and 

 Wildlife Service (USFWS) and NEPA requirements for analysis 

 of prairie dog/ferret complexes, the potential 

 reintroduction of ferrets and evaluation of other 

 endangered, threatened or candidate species associated with 

 prairie dog towns. As a result, the BIA completed only an 

 initial investigation for the Environmental Assessment 

 required for prairie dog poisoning on the Reservation. The 

 BIA's Environmental Assessment was published in September, 

 1991. 



Due to budget constraints and lack of funding for 

 overall range improvement, poisoning of prairie dogs has 

 traditionally been the primary management alternative used 

 by the BIA on reservation trust lands. However, under 

 contemporary conditions continued poisoning of prairie dogs 

 in relationship to endangered and threatened species is no 

 longer feasible. Specifically, the USFWS has issued a 

 biological opinion that the proposed poisoning of prairie 

 dogs on the Cheyenne River Reservation would jeopardize the 

 survival and recovery of the black-footed ferret. 



The proposed control measure through limited poisoning 

 on both reservations has also been hindered by threatened 

 litigation from the Defenders of Wildlife and the Sierra 

 Club because it could jeopardize potential recovery of the 

 black- footed ferret and is therefore in violation of the 

 Endangered Species Act. Additionally, these organizations 

 disagreed with the conclusions reached under the NEPA 

 procedures that proposed poisoning would not be a major 

 impact on the environment. 



